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Office of Gas and Electricity Markets (Ofgem)

P-004548 · Statement · Decision date: 23 December 2025 · View Office of Gas and Electricity Markets scorecard
Complaint (AI summary)
Mr O complained that Ofgem inappropriately revoked his access to the renewable heat incentive (RHI) accreditation, causing financial and mental distress.
Outcome (AI summary)
Not upheld. The ombudsman found no serious error, as Ofgem followed its own guidance in revoking Mr O's accreditation.

Full decision details

The Complaint

3. Mr O complains that in May 2025, Office of Gas and Electricity Markets (Ofgem) revoked his access to the renewable heat incentive (RHI) accreditation inappropriately.

4. Mr O says as a result of the above, he has been left financially burdened and suffered stress and mental health issues.

5. Mr O is seeking a review of the decision to revoke RHI accreditation and financial remedy.

Background

6. The RHI is a government program to pay people and businesses to generate and use renewable heat. Mr O was a part of this program. He had an air source heat pump (ASHP) installed at his home in January 2022 and his participation in the RHI scheme started on 11 February 2022. The ASHP pulls heat from outside air and transfers it inside for radiators, underfloor heating and hot water. It is a renewable, efficient home heating/cooling system.

7. On 12 February 2025, Ofgem asked Mr O for further information as he had stated ‘no’ to the question ‘is your heating system in good working order?’ in the year 4 annual declaration form.

8. On 13 February 2025, Mr O replied explaining his ASHP had not been working at temperatures of 4 degrees or lower and it needed to be repaired or replaced.

9. On 17 February 2025, Ofgem asked if the ASHP had been unable to provide heat and/or hot water to his house for a period of more than 24 hours.

10. On 18 February 2024, Mr O replied stating he could try to carry out a statistical analysis of the local weather conditions to find that information. He also asked the intent of Ofgem’s question.

11. On 19 February 2025, Ofgem asked Mr O whether the ASHP has been unable to provide heat for more than 24 hours regardless of the weather conditions and asked for a response within 28 days.

12. Mr O responded on the same day advising the weather was directly linked to whether the ASHP was able to provide heat and explained why. He confirmed there were periods of over 24 hours during which he did not use the ASHP but said he was unsure whether it was actually functioning during those periods.

13. On 20 February 2025, Ofgem confirmed an installation is not eligible for RHI payments if an ASHP is unable to provide heat and/or hot water to the property. It asked for the date it stopped generating heat, the date it was repaired and evidence to show the repair had taken place. Ofgem asked for this information to be provided by 20 March 2025.

14. On 6 March 2025, Ofgem sent Mr O a reminder email. Mr O called Ofgem’s enquiries team that day explaining the repair had not yet taken place. He said he did not know the dates the ASHP had not been able to generate heat. The enquiries team asked him to explain the situation by email and he did this.

15. On 11 March 2025, Ofgem asked again for the dates the ASHP was not providing heat for more than 24 hours. It asked for approximate dates if the exact dates could not be provided and gave a deadline of 20 March 2024. This was extended to 4 April.

16. On 8 April 2025, the deadline was extended again to 22 April and Ofgem advised Mr O that it may revoke his accreditation if the information was not provided by the deadline.

17. On 17 April 2025, Ofgem called Mr O and left a voicemail asking him to respond to its emails by the deadline.

18. Ofgem revoked Mr O’s accreditation on 14 May 2025. It said he did not provide the information it requested within the timescale required which was contrary to the obligations set out in the Domestic and Renewable Heat Incentive (RHI) Scheme Regulations 2014, as amended. In its review response dated 22 July 2025, it upheld its original decision.

Findings

20. Before we decide if we should conduct a detailed investigation of a complaint, we look at whether there are signs the organisation has got something wrong. We do this by comparing what should have happened with what did happen. We have done this and have not found any indications that something has gone wrong.

21. Mr O told us Ofgem’s decision letter which informs him about the revocation of his accreditation states he did not provide the approximate dates the ASHP was unable to provide heat. He states he was not asked for approximate dates though, he was asked for specific dates which he did not have and he did not want to provide wrong information. He said the heating system (the ASHP) was not set up for an individual homeowner to provide that kind of specific information.

22. Mr O said he had photos of when the ASHP was covered in ice and sent these to Ofgem to evidence it was not working with the dates the photos were taken included. He said Ofgem then asked further questions about whether during some hours on those dates it was working. He said although he answered it, this question was very difficult to answer as he did not keep records of that and there was no information to suggest he had to.

23. Ofgem started requesting information and evidence about the dates Mr O’s ASHP was not working on 12 February 2025. We can see that in its email on 11 March 2025, it said he could give approximate dates the ASHP was not providing heat for more than 24 hours if he did not know exact dates. Ofgem extended the deadline to provide this information from 20 March to 4 April. It extended the deadline again to 22 April. Ofgem also left a voicemail asking him to respond by the deadline.

24. Ofgem said the reasons for revoking the accreditation were that Mr O failed to comply with regulation 44(1) which states the participant must provide any information required to discharge its functions. It said he also failed to comply with regulation 44(3) which states a participant should provide any information requested within 28 days of the request or a later date that Ofgem may specify.

25. In its email to Mr O on 16 June, Ofgem states Mr O confirmed 10 dates on which the ASHP did not function as required in his review request. It explained that it needed the information to discharge its functions as it needed to calculate any payments he was not eligible for due to his ASHP not being able to provide heat for periods over 24 hours.

26. Ofgem’s review response dated 22 July 2025, upheld the original decision. The response states ‘this is because you had access to the approximate dates your heating system was not able to provide heat, but you did not provide them within the deadline we specified of respond to our requests’. It states Mr O therefore repeatedly failed to comply with his ongoing obligation as set out in regulation 44.

27. We have considered this matter in detail. Chapter 3 of the DRHI essential guide states ‘you must comply with any other administrative requirements specified by us. This covers any requirements necessary to establish your ongoing eligibility, for example, if we require further information to evidence that you are meeting your ongoing obligations’.

28. Section 7 of the DRHI essential guide states a participant must meet its ongoing obligations whilst it is a participant of the scheme. It further states, ‘If we suspect any failure to meet ongoing obligation, we would suspend payments whilst we investigate. If the non-compliance is confirmed, and depending on its severity we may:

• suspend payments temporarily or withhold them permanently • revoke the installation’s accreditation • recover overpayments’.

29. The guidance above makes it clear that the onus is on the participant to ensure they comply with their ongoing obligations, one of which is to provide any information required within 28 days of the request or another date specified.

30. Mr O did provide the dates that the ASHP was not functioning properly or at all on 10 dates with photographic evidence, but this was after Ofgem’s deadlines to provide the information had passed.

31. We consider Ofgem did consider the photos he sent as evidence of the ASHP not working on particular days, as we can see consideration of this in its review response. Ofgem states, that after it received Mr O’s review request, it ‘then asked you about the photographic evidence you had used to determine the dates you have provided in your review request. You responded that you had taken the photos and videos of the ASHP on the dates when the defrost function had not been working. You said on these dates, the ASHP had been unable to provide heat for the whole day’. This shows it considered the information Mr O provided.

32. In light of the above, we consider Ofgem acted in line with regulation 44 in revoking the accreditation. Mr O told Ofgem the dates provided with the photos were the contemporaneous dates the ASHP was covered in ice, therefore we can reasonably believe Mr O had access to information that the ASHP not working before he provided it in June 2025.

33. We understand Mr O’s frustrations around not wanting to provide incorrect information but we think he could have provided whatever information he did have at the time it was requested. In any event, Ofgem did clarify he could provide approximate dates the ASHP was not functioning in its email dated 11 March as mentioned above.

34. Whilst Mr O is very focused on the issue being that he could not provide exact dates the ASHP was not functioning, we do not think this is the key issue here. It was his responsibility to provide the information anyhow to fulfil his obligations as a scheme participant. We consider he could have provided some information to fulfil Ofgem’s request within the timescale but did not.

35. Having reviewed the correspondence, we think Ofgem also gave Mr O multiple opportunities to provide the requested information, which is evidenced through the extensions of time it granted. We therefore cannot see any evidence that it did not act reasonably.

36. Based on the above, we have not seen any indications of maladministration in the way Ofgem followed its processes. We consider it acted in line with regulation 44 as set out above and its review response in upholding the original decision was justified based on the evidence we have seen.

37. We understand this decision may be a disappointing outcome for Mr O. We hope we have clearly explained the reasons for our decision. We thank Mr O for bringing his concerns to our attention.

Our Decision

1. We have carefully considered Mr O’s complaint about Office of Gas and Electricity Markets. We have seen no indication that anything went seriously wrong as we consider Ofgem followed its guidance in relation to revoking Mr O’s accreditation in the renewable heat incentive scheme and upholding its original decision about this.

2. We are sorry to hear that Mr O has suffered financially and mentally due to the incident he complains about. We have set out our full decision reasoning below which we hope provides Mr O with some reassurance.

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